Thought-provokinganalysis and opinion on federal tax issues

Disguised Sales and the Centralized Partnership Audit Regime

June 3, 2020

by Monte A. Jackel

I posted this recently in the Procedurally Taxing blog. It deals with disguised sales to partnerships, the BBA centralized partnership audit regime, whether the selling partner’s gain is part of the imputed underpayment, and the due process issue raised if the selling partner is separately audited on the sales gain which is not treated as part of the imputed underpayment but the partnership proceeding determination that there was a sale is binding on the seller partner. I thought this would be of interest.